Effective Date: December 15, 2016
Special Note: Exciting changes are afoot at TriMet! Our new Hop Fastpass ™ electronic fare system makes it faster, easier and more convenient to take public transit in the Portland metro area. As a result, we’ve recently updated this privacy notice. Please take a moment to review it.
This Privacy Notice covers:
- An introduction to our privacy practices.
- A description of the information TriMet collects.
- An overview about how TriMet uses your information.
- Disclosures regarding third parties with whom TriMet shares your personal information.
- A summary of what security procedures we’ve implemented.
- Instructions for your choices regarding our use of your information.
- TriMet’s Do Not Track policy.
- Other important information, including how we communicate changes to this Privacy Notice.
You may also wish to review the Frequently Asked Questions section for technical information about the Hop Fastpass ™ electronic fare system and other TriMet services.
TriMet operates a variety of online and electronic services to further our mission of providing a safe, dependable and easy-to-use transit system. TriMet collects various information about you through its websites, mobile apps and other electronic channels. We protect your personal information and generally do not share it with unaffiliated third parties, except as detailed below.
TriMet operates public transportation services in the Portland metro area. In cooperation with Clark County, Washington’s C-TRAN and the City of Portland’s Streetcar, TriMet connects people with their community. As part of TriMet’s mission to provide a transit system that is safe, dependable and easy to use, TriMet offers various services, including this website, various mobile applications (“apps”) and other electronic offerings (collectively referred to as the “Services”). Some of the Services require you to provide personal information, such as your name and contact information, and some of the Services automatically collect information from your device, such as geolocation and browser information.
We protect your personal information and will only provide it to third parties (1) as stated in this notice, (2) to provide you with Services or products you order and (3) as permitted or required by law.
As used in this Privacy Notice, the term “personal information” applies only to information, alone or in combination, that can identify you individually.
This Privacy Notice applies to information collected when you interact with TriMet Services in the following ways:
- Through TriMet websites, including TriMet.org and myhopcard.com.
- Through TriMet-operated mobile apps, including Hop Fastpass ™ and TriMet Tickets.
- Through TriMet Hop Fastpass ™ electronic fare cards, including tapping a fare card.
- Through TriMet-operated websites, including TriMet’s online store at www.zazzle.com/ridetrimet.
This Privacy Notice does not apply to information collected by C-TRAN or Streetcar.
2. Information Collected
TriMet collects the personal information you provide when you interact with TriMet (such as by creating an account and using the Services). In addition, certain information – such as location information, device details and cookie data – is transmitted to TriMet automatically when you use the Services. Aggregate and non-personal information that cannot be used to identify you individually helps TriMet deliver relevant and agile Services – this Privacy Notice does not restrict how TriMet uses such non-identifiable data. TriMet does not knowingly collect personal information from users under the age of 13.
2.1 Account Information
2.2 Payment Card Information
When you buy fares or products, or load your Hop Fastpass ™ card via the Services, you will be asked to provide payment card details. TriMet uses a third-party payment processor to handle payment card transactions, and therefore does not store or process your payment card information.
2.3 Interacting with TriMet
You provide personal information when you interact with TriMet. For example, when you contact TriMet by email, we may collect your email address and any other personal information you provide. When you subscribe to one of our electronic newsletters, you must provide your name and a valid email address. If you participate in a TriMet promotion, you may be required to provide certain contact information. You may also provide your address, telephone number and organizational affiliation. If you apply for employment online, we will collect personal information such as your name, address, resume and other employment-related information. However, we use this information solely for consideration of your application.
2.4 Using the Services
TriMet collects certain information automatically when you use the Services. For example, your device’s geolocation information may be collected so we can alert you when your bus, train or streetcar is arriving if you use our TransitTracker or Trip Planner features. (Geolocation information is encrypted and generally not subject to public records requests.) We also receive the internet protocol (IP) address of your computer, smart-device or the proxy server or router that you use to access the internet, operating system details, type of web browser, mobile device details (including your mobile device identifier provided by your mobile device operating system) and search data.
2.5 Cookies and Web Beacons
We may also automatically collect certain information through the use of “cookies.” Cookies are small data files that are stored on a user's hard drive at the request of a website to enable the site to recognize users who have previously visited it and retain certain information such as customer preferences and navigation history. If we combine cookies with or link them to any of the personal information, we would treat this combined information as personal information. If you wish to block, erase or be warned of cookies, please refer to your browser instructions to learn about these functions. However, if your browser is set to reject cookies, some of the features of the Services may not function.
We may also use third parties to provide certain analytics services, including analyzing non-personally identifiable usage and statistical information from users, such as the user's browser type, operating system and demographic information, as well as information about how you interact with the Services. These third parties may place cookies, web beacons or other devices on your computer or device to collect information that may be used, among other things, to deliver advertising targeted to your interests across different websites and to better understand the usage and visitation of our Services and the other sites tracked by these third parties.
2.6 Aggregate, Non-Personal Information
TriMet collects certain aggregate information, including statistical information about how users access and interact with the Services (e.g., which Service features and web pages are most accessed, which bus and rail lines are most used, how many people open our newsletters, which technical issues affect our users, etc.). This information cannot be used to identify you individually, though we may link this information to your TriMet profile. This Privacy Notice does not limit how TriMet may use aggregate or non-personal information.
2.7 Information from Children Under 13
TriMet complies with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and the Federal Trade Commission’s rule interpreting COPPA (16 CFR § 512). The Services are not directed at children, and we do not knowingly collect any personal information through the Services from children under 13 years of age. If we learn that a child under 13 years of age has provided us with personal information, we will delete this information from our databases.
3. How TriMet Uses Your Personal Information
By using the Services and providing your personal information, you are giving TriMet permission to collect and use the information as described in this Privacy Notice. We use your personal information to communicate with you and to provide, develop and customize the Services. For example, if you use the trip planning feature, TriMet may use your location to guide you to the nearest transit stop. TriMet may also combine information we receive from one service with information provided through another service. For example, if you contact us from an email address we have on file, we will add the details of that communication to your profile.
3.1 Consent to TriMet
By providing personal information to TriMet when you create or update your account and interact with the Services, you are expressly agreeing to our use and processing of your personal information as set out by this Privacy Notice. You can withdraw or modify your consent to our continued collection of your personal information by changing your account settings, by closing your account and/or by deleting the Services from your device(s). TriMet will retain previously collected data in accordance with its data retention policies and applicable laws.
3.2 Communications from TriMet
We communicate with you through email, notices posted through the Services, and other means available through the Services, including mobile text messages and push notifications. Examples of these communications include:
- Initial communications: Informing you how to use the Services, including any new features of the Services.
- Service communications: Alerting you about the availability of the Services and transit systems, confirming purchases and providing information about other issues related to our Services. You cannot opt out of receiving service messages from us.
- Promotional communications: Sharing information about TriMet’s products and services.
- Response communications: Responding to an inquiry by you, either through the Services, social media or other channels.
3.3 Providing, Developing and Customizing the Services
TriMet uses your personal information to provide you with the Services you’ve requested. For example, if you sign up for an electronic newsletter, we use your name and email address to send you the newsletter. If you use our trip planning feature, we may use your location information. We may also use your personal information to improve features of the Services, such as when you provide feedback to TriMet customer service agents. We also use this information to track potential problems and trends and to customize our support responses to better serve you. We do not share personal information provided during customer service interactions for third-party advertising purposes without your permission.
TriMet may combine personal information you provide through different interactions with TriMet and TriMet’s service providers in order to provide a more customized and relevant experience. For example, if you contact us from an email address we have on file, we will make a note of that communication in your customer profile.
When you register for a Service, TriMet uses your identifying information to set up your account. TriMet also uses personal information to enforce and protect its rights, including in connection with electronic citation processing.
4. How TriMet Shares Your Personal Information
TriMet does not sell, rent or disclose personal information to any unaffiliated third party, with the limited exceptions of service providers, C-TRAN and Streetcar, and recipients who are entitled to the information for legal or safety reasons.
4.1 Service Providers and Transportation Partners
TriMet may share personal information with service providers and transportation partners that assist TriMet in providing, improving and marketing the Services. For example, TriMet may engage an email service provider to manage our electronic newsletters, a technology company to build software or apps, or an analytics provider to study user habits. TriMet may also share your personal information with transportation partners to provide you with a service you requested through a partnership or promotional offering made by a third party or us. These third parties have limited access to your information only to perform these tasks on our behalf.
4.2 C-TRAN and Streetcar
If you use the Hop Fastpass ™ system in connection with C-TRAN or Streetcar services, TriMet may share your personal information with C-TRAN or Streetcar so that C-TRAN and Streetcar may provide and improve their own services. C-TRAN or Streetcar may only use your personal information for those purposes. Information that you provide directly to C-TRAN or Streetcar is governed by their respective privacy policies.
4.3 Disclosures Required by Law or for Compliance Reasons
We may need to disclose your personal information to law enforcement agencies, but only when compelled by law, subpoena or other legal process. In addition, we may disclose certain personal information if we have a good faith belief that disclosure is reasonably necessary to:
- Enforce the Terms of Service or the TriMet Code, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Services.
- Exercise or protect the rights, property or safety of TriMet personnel, users, or others.
We’ll attempt to notify you about legal demands for your personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. Unless compelled by law, TriMet will not provide personal information to the U.S. Immigration and Customs Enforcement (ICE) or any similar agency for immigration enforcement purposes.
4.4 Public Records Laws
You should be aware that TriMet is a public agency and is subject to public records laws. Personal information provided by you may be subject to disclosure pursuant to public records laws, unless the information is exempted by law. You should not provide personal information if you are concerned about disclosure of your information under those laws.
We understand your security concerns and strive to take appropriate precautions. However, the internet is inherently vulnerable and we cannot guarantee absolute security.
We take precautions to protect your personal information. For example, we encrypt certain communications through our Services with 128-bit encryption. However, given the nature of the internet and the fact that network security measures are not infallible, we cannot guarantee the security of your information.
If you have any questions about the security of our Services, you can send a message to firstname.lastname@example.org.
6. your choices
TriMet offers various mechanisms for opting out of certain information sharing and communications.
6.1 Hop Fastpass ™ Dashboard
If you create a Hop Fastpass ™ account, you may change your information by logging into and managing your account.
6.2 Opting Out
If you no longer wish to receive communications from TriMet, you can do so by:
- Promotional communications: Opt out of promotional messages by unsubscribing from the email you received, changing your preferences at trimet.org/email or (with regards to Hop Fastpass ™ communications) calling 888-MYHOPCARD.
- Text messages: Replying STOP to the applicable text message.
Note that you cannot opt out of initial or service communications.
Most mobile devices allow you to prevent real time location data from being sent to us. If you turn off location services, not all features of the Services will function.
If you don’t want to receive cookies, you can change your browser settings on your computer or other device. Note that the Services will not work properly without cookies.
To find out more about cookies, see https://en.wikipedia.org/wiki/HTTP_cookie. This site is not part of TriMet and we make no assurances that the information it provides is complete, current or error-free.
6.5 Contacting TriMet for Changes
You may also contact us at email@example.com to find out what personal information we have about you and to change your personal details.
7. Do Not Track
Do Not Track (“DNT”) signals are a feature offered by various browsers, which sends a signal to a website not to track the user when he or she leaves that website. TriMet does not respond to DNT signals at this time.
8. Important information
If TriMet links to third-party websites, we cannot control the privacy practices of unaffiliated companies. Please review those companies’ terms carefully. If we make material changes to this Privacy Notice, we will notify you. TriMet, a Portland, Oregon-based transit service provider, does not intend for its Services to be accessed by users who reside outside the United States. Any questions about this notice can be sent to firstname.lastname@example.org.
8.1 Links to Other Websites
8.2 Notification of Changes
We may occasionally change this Privacy Notice. If we make material changes in the way we treat your personal information, we will provide notice to you through the Services or some other means, such as email to the email address used for your Services account. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes, please delete the Services from your devices and stop using the Services. Our current Privacy Notice applies to all information that we have about you and your account. Using our Services after a notice of changes has been communicated to you or published on our Services constitutes consent to the changed terms or practices.
8.3 Services Provided in the United States
TriMet provides local transit services in the U.S. metro area of Portland, Oregon. The Services are not intended for users based outside the United States. If you reside outside the United States, you acknowledge that your personal information is processed within the United States and you agree to such processing as described in this Privacy Notice.
8.4 Contact Information
If you have questions about anything in this Privacy Notice, contact TriMet at email@example.com.